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<strong>CONNECT</strong><br />

<strong>March</strong> <strong>2022</strong><br />

<br />

A Monthly Publication for the <strong>Healthcare</strong> <strong>Compliance</strong> Community<br />

FAQ Corner:<br />

How should we handle employees<br />

who won’t complete training as<br />

assigned?<br />

Infographic:<br />

<strong>Compliance</strong> Tips for <strong>Healthcare</strong><br />

Board Members<br />

Hardware Hacking<br />

in <strong>Healthcare</strong>:<br />

Expert Insights<br />

<strong>Healthcare</strong> <strong>Compliance</strong> Policies:<br />

Best Practices for Management<br />

and Distribution<br />

Delaware Law School and <strong>First</strong><br />

<strong>Healthcare</strong> <strong>Compliance</strong> Announce<br />

Presenters for 5th Annual<br />

<strong>Healthcare</strong> <strong>Compliance</strong><br />

Symposium<br />

1st Talk <strong>Compliance</strong>:<br />

<strong>Healthcare</strong> and Technology<br />

Negotiations


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experience. It’s a simple way to help us grow and<br />

improve.<br />

We appreciate your support and look forward to<br />

hearing from you!<br />

In This Issue:<br />

<strong>Compliance</strong> Super Ninja<br />

FAQ Corner: How should we handle employees<br />

who won’t complete training as assigned?<br />

Infographic: <strong>Compliance</strong> Tips for <strong>Healthcare</strong><br />

Board Members<br />

Hardware Hacking in <strong>Healthcare</strong>:<br />

Expert Insights<br />

2<br />

<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>


<strong>Compliance</strong> Super Ninja <br />

Jennifer Colucciello<br />

<strong>Compliance</strong> Officer/Operations Director<br />

Kidney Care Specialists, LLC<br />

How would you describe your experience with <strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>?<br />

The 1stHCC platform has helped make tracking extremely easy, especially since we have 4 very different<br />

divisions. This platform has allowed for streamlining of compliance items and tracking. Having updates<br />

made due to new regulations is relatively quick and painless which helps us maintain compliance as new<br />

requirements are instituted. Definitely helps us stay compliant while doing so efficiently!<br />

What do you enjoy most about working with Kidney Care Specialists, LLC?<br />

Nephrology itself has such a huge impact on our patients and their caregivers. The KCS team is highly<br />

motivated and dedicated to treating our patients in the best way possible with the best care possible! Truly an<br />

honor to be part of this team!<br />

Would you rather read an awesome book or watch a good movie? Why?<br />

Definitely a book! Helps my entire mind escape for a bit to another time and place :)<br />

<strong>Healthcare</strong> <strong>Compliance</strong> Policies:<br />

Best Practices for Management and<br />

Distribution<br />

1st Talk <strong>Compliance</strong>: <strong>Healthcare</strong> and<br />

Technology Negotiations<br />

Delaware Law School and <strong>First</strong> <strong>Healthcare</strong><br />

<strong>Compliance</strong> Announce Presenters for 5th<br />

Annual <strong>Healthcare</strong> <strong>Compliance</strong> Symposium<br />

Contact Toll Free: 888-54-FIRST 3


FAQ Corner<br />

How should we handle employees who won’t complete training as assigned?<br />

<strong>Compliance</strong> should be a condition of employment. And as part of the Code of Conduct sample we provide,<br />

employees are required to complete compliance training. Employers may wish to enforce their training<br />

requirements through discipline. Discipline may include a verbal warning, written warning, suspension, up<br />

to and including termination. Of course, if your organization has a progressive discipline policy, it must be<br />

followed when disciplining employees (we provide a sample compliance program disciplinary action policy<br />

within the <strong>Compliance</strong> Policies and Procedures Sample). It is also important to be consistent in meting out<br />

discipline so as not to run afoul of discrimination laws.<br />

Explore the FAQs tab in your compliance solution<br />

to find answers to your compliance questions!<br />

CLIENT<br />

ALERT<br />

The Most Comprehensive<br />

<strong>Healthcare</strong> <strong>Compliance</strong> Course<br />

The Fundamentals is a user-friendly, four-module<br />

online course designed to help healthcare professionals<br />

understand the essential principles and practices of<br />

compliance.<br />

BUY COURSE NOW<br />

4<br />

<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>


Contact Toll Free: 888-54-FIRST 5


Hardware Hacking in <strong>Healthcare</strong>:<br />

Expert Insights<br />

Catherine Short<br />

John Shegerian, Co-Founder, Chairman and<br />

CEO of ERI recently shared expert insights in<br />

the presentation, The Insecurity of Everything:<br />

Hardware Hacking Trends.<br />

Data security regulations now exist in all fifty states,<br />

federally, and internationally. Risks are universal as<br />

all businesses and individuals including healthcare<br />

professionals utilize devices that retain data that<br />

becomes vulnerable to cybercriminals. The healthcare<br />

industry and hospitals are increasingly at risk for<br />

ransomware and other types of cyberattacks. Several<br />

recent examples illustrate the risks and repercussions<br />

that result from a combination of inadequate resources<br />

and a lack of clear and effective cybersecurity guidelines.<br />

The pandemic has amplified many of the cyber risks<br />

associated with breaches and hardware hacking in<br />

healthcare. According to Shegerian, “Many of you are<br />

working from home or working in some sort of hybrid<br />

situation. We’ve learned that due to COVID, people<br />

started working for home without all the guardrails that<br />

are typically set up by CTOs in hospitals and healthcare<br />

settings. Workers at home unfortunately, started using<br />

their personal hardware, tablets, cell phones, laptops,<br />

desktops, for business<br />

purposes, and their<br />

business hardware, for<br />

personal purposes, it<br />

just happens when we<br />

have time crunches,<br />

when something breaks<br />

down, and we must go<br />

to a backup plan. That<br />

means there’s a cross<br />

contamination when data from one platform gets on to<br />

another. There’s a cross contamination of your personal<br />

data onto your professional hardware. And vice versa.<br />

This means if you work for a healthcare organization, or<br />

agency, and you believe there’s a chance that you’ve<br />

had cross contamination, which I’d be shocked if there<br />

wasn’t please adhere to the protocols provided by your<br />

Chief Technology Officer. Make sure data and devices are<br />

responsibly destroyed when it comes to end of life, not<br />

put on eBay or Craigslist.”<br />

To learn more, please stay tuned for John’s future<br />

podcast with host Catherine Short on 1st Talk<br />

<strong>Compliance</strong>.<br />

6<br />

<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>


Navigating Workplace Violence<br />

Prevention Under OSHA<br />

Workplace violence is a serious issue, especially in<br />

healthcare facilities. The Occupational Safety and Health<br />

Administration (OSHA) responded in 2015 by updating and<br />

publishing their guidelines on how to best prevent workplace<br />

violence. The OSHA workplace violence prevention<br />

guidelines help employees and employers alike by providing<br />

the necessary steps to maintain a safe work environment.<br />

DOWNLOAD NOW<br />

COVID-19 <strong>Healthcare</strong><br />

<strong>Compliance</strong> Updates<br />

In response to the global outbreak of the novel coronavirus<br />

disease (COVID-19), the Secretary of Health and Human<br />

Services declared a public health emergency on January 31,<br />

2020. Federal agencies have taken action by issuing updates<br />

and guidance to navigate the crisis. This ebook provides<br />

healthcare providers with important developments and<br />

resources that impact federal healthcare laws.<br />

DOWNLOAD NOW<br />

Contact Toll Free: 888-54-FIRST 7


<strong>Healthcare</strong> <strong>Compliance</strong> Policies:<br />

Best Practices for Management<br />

and Distribution<br />

<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong> Staff<br />

Purposes of Policies in <strong>Healthcare</strong><br />

Organizations<br />

Many healthcare organizations operate under a<br />

comprehensive set of policies and procedures that<br />

address a wide range of compliance-related issues,<br />

including physician relationships, conflicts of interest,<br />

OSHA and HIPAA Privacy and Security. These<br />

policies and procedures should be available to every<br />

employee and provider.<br />

Specific standards set by an entity as well as the<br />

elements of an effective compliance program<br />

provided by OIG/HHS offer frameworks for roles and<br />

committees to ensure consistency and integration<br />

of compliance activities and the effectiveness of the<br />

overall compliance program.<br />

A well-managed set of policies is critical to the wellbeing<br />

of any healthcare institution. Proper policies<br />

support activities by communicating expectations,<br />

establishing a culture of compliance, protecting<br />

in litigation matters, and ensuring the welfare of<br />

patients and staff.<br />

Important purposes of policies in the healthcare<br />

setting include:<br />

1. Provide the framework for the key elements of<br />

the compliance program<br />

2. Promote and support ethical behavior among<br />

staff<br />

3. Exhibit commitment to compliance and all<br />

regulations governing the organization<br />

Management and Distribution of<br />

<strong>Healthcare</strong> <strong>Compliance</strong> Policies<br />

In addition to creating, communicating, and<br />

maintaining policies within a healthcare organization,<br />

it is imperative to take steps to manage and<br />

distribute the policies effectively.<br />

1. Assign Responsibility<br />

An individual should be responsible for managing<br />

policies within the healthcare organization.<br />

Depending on the size of the entity, it may be<br />

either a full or part time position.<br />

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<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>


2. Control Access<br />

For the purposes of efficiency and privacy and<br />

security, the administrator should have full<br />

control when it comes to providing access for<br />

reading and editing policies.<br />

3. Track Policy Updates<br />

Tracking policy changes becomes a necessity<br />

to provide accurate information to compliance<br />

questions or auditors.<br />

<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong> offers several solutions<br />

that provide customizable sample Policies and<br />

Procedures. In addition, our Document Storage zone<br />

allows compliance personnel to upload, organize<br />

and distribute documents via the Training Zone for<br />

employee attestation. To learn more contact us<br />

today!<br />

C. Trey Scott, Coordinating Attorney at<br />

Kennedy, Attorneys & Counselors<br />

<strong>Compliance</strong><br />

at Law<br />

Toolkit<br />

will present Under Pressure: Reporting<br />

Appeals for the Fifth Circuit.<br />

Requirements with OCR for Breaches at the<br />

upcoming Virtual<br />

<strong>Healthcare</strong><br />

HIPAA<br />

compliance<br />

Privacy and Security<br />

amidst COVID-19 presents new challenges<br />

for hospitals and healthcare providers. At top importance is the<br />

Summit 2021 on November 18.<br />

Summit!<br />

question of how to slow or stop the spread of COVID-19, while<br />

Trey received his Bachelor ensuring of Science and that Master your of organization stays compliant.<br />

Business degrees from Texas Tech University and his<br />

Juris Doctorate from Texas Now more Wesleyan than University ever, your School compliance department needs to have the<br />

of Law (now Texas necessary A&M University tools to School help of track, Law.) analyze, While and respond to compliance challenges.<br />

in law school, Trey To was help a member navigate of the arbitration process, we’ve gathered our best COVID-19 resources<br />

competition team as well below. as a student If you bar need association further assistance, please contact us here.<br />

representative. He also was a law clerk to the 106th<br />

District Court of the State of Texas. Trey has significant<br />

experience in healthcare law. This experience includes:<br />

COVID-19 <strong>Healthcare</strong><br />

VIEW TOOLKIT<br />

United States District Courts for the Northern, Southern,<br />

Eastern, and Western Districts of Texas. Trey is also<br />

licensed to practice before the United States Court of<br />

Click here for more information or to register for the<br />

medical malpractice litigation, administrative and<br />

regulatory appeals and disputes, professional board<br />

matters, and overpayment disputes. Trey is licensed to<br />

practice law before Texas State Courts as well as the<br />

Contact Toll Free: 888-54-FIRST 9


Delaware Law School and<br />

<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong><br />

Announce Presenters for<br />

5th Annual <strong>Healthcare</strong><br />

<strong>Compliance</strong> Symposium<br />

April 28, <strong>2022</strong><br />

Catherine Short<br />

Attorneys and experts from various<br />

specialties and firms throughout the United<br />

States will serve as instructors for the<br />

educational event.<br />

WILMINGTON, Del. (PRWEB) January 30, <strong>2022</strong> --<br />

The 5th annual <strong>Healthcare</strong> <strong>Compliance</strong> Symposium<br />

will be offered virtually. A broad range of timely<br />

topics will be covered including HIPAA, OSHA,<br />

Fraud, Waste and Abuse, Ethics, human resources<br />

compliance, and current challenges related to<br />

COVID. Attorneys, compliance officers, managers,<br />

nurses, medical assistants, healthcare professionals,<br />

business associates, and students are encouraged to<br />

attend. This convenient online learning event offers<br />

multiple CEUs and CLE in Delaware, New Jersey, and<br />

Pennsylvania.<br />

Attorneys and experts listed below from various<br />

specialties and firms throughout the United States<br />

will serve as instructors for the educational event:<br />

• Stephen D. Bittinger, Esq.<br />

• Emily Johnson, Esq.<br />

• Kathleen W. McNicholas, MD, JD, CHC, CCEP<br />

• Elizabeth Sullivan, Esq.<br />

• Rachel V. Rose, JD, MBA<br />

• Lauren Moak Russell, Esq.<br />

• Catherine Walters, Esq.<br />

The symposium is a joint effort to provide resources<br />

for professionals facing the challenges of the everchanging<br />

healthcare industry. The event will be held<br />

on April 28, <strong>2022</strong>, with online access for virtual<br />

attendance. Discounts apply for Delaware Law School<br />

Alumni and clients of <strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>.<br />

Learn more and register now.<br />

About Delaware Law School: Widener University<br />

is a metropolitan university that connects curricula<br />

to social issues through civic engagement. Dynamic<br />

teaching, active scholarship, personal attention,<br />

applied leadership, and experiential learning are key<br />

components of the Widener experience. Delaware<br />

Law School is the <strong>First</strong> State’s only law school,<br />

providing a Juris doctor, legal graduate and paralegal<br />

10<br />

<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>


degree programs with an emphasis on developing<br />

legal professionals who reflect the Delaware Way and<br />

its traditions of civility, integrity and mutual respect.<br />

The school offers signature programs in corporate<br />

and business law, environmental law, family health<br />

law and policy, trial advocacy, and dignity rights.<br />

About <strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>: Founded<br />

in 2012 by a nurse attorney, the <strong>First</strong> <strong>Healthcare</strong><br />

<strong>Compliance</strong> software solution creates confidence<br />

among compliance professionals through education,<br />

resources, and support in the areas of HIPAA, OSHA,<br />

human resources compliance, and fraud waste and<br />

abuse laws. Serving clients across the United States,<br />

the company’s evolving platform provides real-time<br />

insight for board reporting<br />

For more information please visit<br />

https://1sthcc.com/<br />

Contact Information<br />

Catherine Short<br />

<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong><br />

http://1sthcc.com<br />

302-416-4329<br />

<strong>Healthcare</strong><br />

<strong>Compliance</strong><br />

Symposium<br />

April 28, <strong>2022</strong><br />

REGISTER NOW<br />

Contact Toll Free: 888-54-FIRST 11


Risk Management Considerations for<br />

the <strong>Healthcare</strong> <strong>Compliance</strong> Officer:<br />

Training, Incident Management, Governing Boards,<br />

and Measures Unique to COVID-19<br />

It’s no secret that healthcare is one of America’s most heavily regulated<br />

industries with substantial fines and penalties for non-compliance. Complex<br />

regulations and mandates make compliance management a necessity.<br />

<strong>Healthcare</strong> organizations particularly rely on the skills and attributes of their<br />

compliance officer to navigate the expansive regulatory framework.<br />

DOWNLOAD NOW<br />

12<br />

<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>


Referral Appreciation Program<br />

Receive a $50 gift card* when you refer a client!<br />

<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong> is delighted to offer a Referral Appreciation<br />

Program to say thank you for helping us to continue to grow. For each new 1st<br />

Professional or 1st Premium client originating from a referral, <strong>First</strong> <strong>Healthcare</strong><br />

<strong>Compliance</strong> will provide a $50 gift card as a token of appreciation.<br />

LEARN MORE<br />

Contact Toll Free: 888-54-FIRST 13


hosted by Catherine Short<br />

Catherine Short converses with Rachel V. Rose, JD, MBA, principal with Rachel V. Rose – Attorney at Law,<br />

P.L.L.C., Houston, TX and Bruce J. Lynskey, Co-Founder at ePrevenir, on the topic of “Negotiations in<br />

<strong>Healthcare</strong> and Technology.” Negotiating occurs in every facet of business and law. From contractual<br />

negotiations through settlement negotiations, it is a delicate dance. There are a variety of classic negotiation<br />

techniques, which include extreme posturing and “anchoring”. <strong>Healthcare</strong> and cybersecurity present unique<br />

challenges because of the looming exposure to a government investigation and either a civil and/or criminal<br />

action, even if a settlement is reached between two private parties. Here we will discuss approaches when<br />

negotiating contracts, settlements, and other items, which arise in healthcare and the cybersecurity industries.<br />

Listen weekdays at<br />

7:30am, 3:30pm, 11:30pm ET<br />

Check out our Show Page!<br />

Looking for the latest compliance insights?<br />

Subscribe to our feed and don’t miss a thing!<br />

14<br />

<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>


WORD SEARCH<br />

H J D O Q K Q N O I T A I C E R P P A Q<br />

L R C Z I M A F X Q Y X M E A P D O I H<br />

Y H W L W C R S T H G I S N I G Q F V M<br />

R E E N O I T A N I M I R C S I D C M L<br />

E A D W R M T T R A C K I N G M N Z T X<br />

H L J J P A N Q G T F Z Q U D N Y H I E<br />

N T P U A N E Z G R H S O K D X A D M F<br />

I H Q V K Y D A E M P L O Y M E N T V K<br />

I C R Q J D I J H H B J A Z Q M O P C K<br />

K A P X P V C M A N A G E M E N T B U Z<br />

P R E S P O N S I B I L I T Y R Y L T Y<br />

O E I G N T I U S W C R I T I C A L H P<br />

L L W J O T S V T S Y O M B Z R M N S U<br />

I K G J D C H A L L E N G E S U V E O W<br />

C C C O M P L I A N C E M U J I B H D N<br />

I H S W J L A V H Q U L E O C Y F G E X<br />

E M L X K T Z U R P I C C C I X J D L R<br />

S A C S L I G J B W W L S J N Z F B S Z<br />

D P T N P N S L A N O I S S E F O R P M<br />

X V T T D P D Q F D G K L V G E G G H T<br />

HEALTHCARE COMPLIANCE TRACKING<br />

EMPLOYMENT DISCRIMINATION MANAGEMENT<br />

INCIDENT APPRECIATION CHALLENGES<br />

PROFESSIONALS DYNAMIC POLICIES<br />

CRITICAL RESPONSIBILITY INSIGHTS<br />

Contact Toll Free: 888-54-FIRST 15


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16<br />

<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>

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